Fire safety information London boroughs expect at planning

Fire safety planning in London runs on two separate tracks, and architects regularly submit for one and get held up by the other. Policy D12 of the London Plan 2021 applies to every development proposal in Greater London, whatever its height. The national fire statement at Planning Gateway One applies only to relevant buildings of 18 metres or seven storeys and above, and it comes with a prescribed form and a statutory consultee. A six-storey block in Hackney needs the first and not the second. Getting that distinction right at the start saves a validation query and a wasted fortnight.

What London Plan policy asks for at application stage

Policy D12 Part A asks all development proposals to achieve "the highest standards of fire safety" and then lists what the submission has to address. In practice a borough case officer is looking for a written statement that covers the building's construction and the materials used, the means of escape for all building users and the suitability of evacuation strategies, passive and active fire safety measures, access and facilities for the fire service, and how the building can be modified in future without compromising any of it.

Part B goes further for major development. Those proposals are expected to arrive with a fire statement prepared by a suitably qualified assessor who is independent of the design team. The Mayor has published London Plan Guidance on fire safety that sets out the expected content and the author's competence, and it is worth reading the current version on london.gov.uk before you scope the work, because the guidance has been revised since the Plan was adopted.

Two mistakes recur. The first is a document that describes Building Regulations compliance and stops there, which answers a different question. Planning is interested in whether the layout, massing, access and escape strategy work at all, not whether the detailed design can be certified later. The second is a statement that arrives without the drawings it refers to.

How the national fire statement differs

Article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015 requires a fire statement with an application for planning permission for development involving a relevant building. The test is a building containing two or more dwellings, or educational accommodation, that is 18 metres or more in height or has seven or more storeys. The statement must be on the form published by the Secretary of State, and the Health and Safety Executive is consulted as the Gateway One statutory consultee.

The two documents overlap but are not interchangeable.

A tall residential scheme in London needs both. Submitting the national form alone will not answer D12, and a D12 statement will not satisfy validation where article 9A applies. Our note on the Fire Statement sets out the form's content in more detail.

Evacuation strategy and lift provision

The evacuation strategy is the part of the submission that actually constrains the plan, so it belongs in the design process rather than at the end of it. A stay put strategy depends on compartmentation holding and on a single stair being defensible. A simultaneous or phased evacuation strategy changes stair widths, refuge provision and alarm coverage, and it changes the core area you need.

Policy D5 Part B5 asks for at least one lift per core to be a suitably designed and sited fire evacuation lift. That has a real plan consequence. An evacuation lift needs a protected lobby, a secondary power supply and a communication system, and retrofitting it after the core is dimensioned rarely works. Where you are testing capacity under the design-led approach, the core is one of the first things to fix, as our piece on optimising site capacity explains.

Approved Document B has been amended to require a second staircase in new residential buildings above 18 metres. Transitional provisions applied to schemes already in the pipeline and they are time-limited, so check the current edition of Approved Document B and its transitional wording rather than relying on advice given on an earlier project.

Access and facilities for the fire service

This section of a D12 statement is often the thinnest, and it is the one a borough highways or fire officer reads most closely. What it needs to show, on a drawing as well as in words:

• Pumping appliance access to the relevant elevations, with the hardstanding, carrying capacity and turning provision the appliance requires.
• Distance from the appliance parking position to the dry riser inlet or the firefighting shaft entrance.
• Hydrant positions, and where a new hydrant is needed, how it will be secured.
• Firefighting shaft arrangement, riser type and the location of the fire service control point.
• How gated or podium access works when the gate is closed and the power is off.

Where the site is served from a narrow street, a private drive or a shared podium deck, say so and show the swept paths. An honest statement that identifies a constraint and resolves it is far stronger than one that implies the problem does not exist.

Who should author the submission

A fire statement is a fire engineering document. Someone with demonstrable fire engineering competence should write it, which in practice means a chartered engineer or a member of the Institution of Fire Engineers at an appropriate grade, working to BS 7974 or the relevant parts of BS 9991 and BS 9999. For major development, the London Plan expects that author to be independent of the designer.

The competence expectations under the Building Safety Act 2022 framework reinforce the point. An architect can set out the strategy in design terms and should, because the strategy is a design matter. The signed statement itself needs the engineer. PlanScope can draft the structure and the policy framing of a Fire Safety Strategy, and that draft is a starting point for the fire engineer, not a substitute for one. A licensed or competent professional is legally required here. You can send a draft for sign-off through the professional directory.

Where Gateway One fits

Gateway One is the planning stage of the three-gateway regime. The Health and Safety Executive responds as a statutory consultee on the fire statement, and its response is a material consideration for the borough. Gateway Two sits before building work starts and is controlled by the Building Safety Regulator. Gateway Three comes at completion.

The practical point for an architect is sequencing. A Gateway One response that asks for changes to escape routes or appliance access lands while the application is live, and the borough will not determine until it has that response. Build the consultation period into the programme rather than treating determination as an eight or thirteen week certainty.

The drawings that answer the policy

Written statements get read once. Drawings get used throughout. The set that answers D12 and the national form without further questions usually includes a fire strategy plan per floor type showing escape routes, travel distances, compartment lines and the firefighting shaft, a core plan showing the evacuation lift, its lobby and its power supply route, a site plan showing appliance access, parking position, riser inlet and hydrants, and an elevation or section annotated with the external wall build-up and any cavity barriers.

Number the drawings in the statement and reference them by number in the text. Case officers lose documents, and a statement that stands alone is easier to re-read at committee.

For a London scheme, start by checking which of the two routes applies to your building and scope the author accordingly. You can browse the report types by category to see what else the site is likely to need alongside them.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.